Before getting into the details of bank regulations, I like to explain the “big picture”
model used by bank regulators. This is shown in Figure 15.1. Capital is required to
cover the difference between the expected loss and a “worst case” loss over sometime time
horizon. For example, the time horizon could be one year and the worst case loss could be
the loss that has only a 0.1% chance of being exceeded.
The key developments in bank regulation that need to be explained are a) the 1988
Basel Accord (Basel I); b) the modification to reflect netting in 1995; c) the 1996 amend-
ment that charged capital for market risk, and d) Basel II. In the material presented in the
book, I have tried to give enough details to give students a good feel for the regulations
without giving so many details that the chapter becomes unreadable. There are a number
of numerical examples to illustrate the workings of Basel I and Basel II. I find it useful to
go through these in class.
The presentation of Basel II focuses on the underlying credit risk model, which is the
factor-based Gaussian copula model covered in Chapter 11. A Harvard Business School
case study that can be used in connection with Basel II is “Basel II: Assessing the Default
and Loss Characteristics of Project Finance Loans (A)” (9-203-035).
Solvency II, the new rules for regulating insurance companies has a similar structure
to Basel II/III. The MCR is analogous to the 4.5% equity capital requirement in Basel
III while and SCR is analogous to the 4.5%+2.5% equity capital requirement (i.e., the
requirement including the capital conservation buffer. A difference between insurance
companies and banks is that insurance companies have exposures on both the asset and
liability side of the balance sheet.
Problem 15.19 can be used for class discussion. Problems 15.20 to 15.22 can be used
as hand-in assignments.
Chapter 16: Basel II.5, Basel III, and Other Post-Crisis Changes
This chapter is an update to Chapter 13 of the third edition. It summarizes some of
the important developments in regulation of banks since the 2007 crisis.
Basel II.5 consists of three changes to the rules for calculating market risk capital. The
rules are a) banks are required to calculate a stressed VaR and use it in the determination
of market risk capital b) banks are subject to an incremental risk charge to ensure that
capital requirements are not reduced when exposures are switched from the banking book
to the trading book, and c) banks are required to use a new method for calculating capital
for exposures that depend on credit correlation.
Basel III consists of new rules for calculating capital for credit risk and two liquidity
ratios that must be adhered to. (The rule concerning CVA can be mentioned for complete-
ness but is probably best handled when Chapter 20 is covered.)
In the fourth edition there are more details on the leverage ratio. Also, G-SIBs,
D-SIBS and SIFIs are discussed,
The chapter covers contingent convertible bonds. These work quite differently from
regular convertible bonds. Regular convertible bonds are exercised when the stock price of
the company issuing the bonds is doing well and the bondholders decide that they would
rather hold equity than debt. Contingent convertible bonds are exercised automatically
when a bank’s equity capital is reaches a low trigger relative to regulatory requirements.
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Dodd-Frank and similar post-crisis legislation in other countries are discussed. Dodd
Frank is a particularly complicated piece of legislation. The material in the book attempts
to summarize the main provisions. The main objective of the legislation is to prevent
future bailouts of financial institutions and protect the consumer. No doubt there will be
crises in the financial sector in the future. They will probably not be similar to the crisis
that started in 2007. Whether Dodd-Frank and the Basel regulations will be successful
in reducing their severity and preventing future bailouts remains to be seen. Students
typically have mixed view on this.
Problem 16.14 can be used as an assignment question on liquidity ratios.
Chapter 17: Fundamental Review of the Trading Book
This chapter is new to the fourth edition. It deals with an important new proposal on
market risk coming out of the Basel committee. There will be many important changes in
the calculation of capital for market risk when the proposal is implemented. Capital will
be calculated from a stressed expected shortfall measure. Liquidity risk will be taken into
account by letting the time horizon used for determining the shocks that are applied to
a market variable depend on the nature of the market variable. The distinction between
the banking book and the trading book will be made more clear cut. The calculation of
capital for trades involving credit risk is changed.
Problem 17.7 is a possible assignment question.
Chapter 18: Margin, Collateral and CCPs
This chapter is new to the fourth edition. The material on the different ways in which
margin accounts are used has been moved from Chapter 5 of the third edition to the
beginning of this chapter. The chapter then moves on to discuss the ways the trading and
clearing of OTC derivatives is handled and the changes that have taken place since the
2007-9 crisis. The chapter also explains how defaults are handled under central clearing
and bilateral clearing.
Problems 18.16 to 18.18 can be used as short assignment questions or discussed in
class.
Chapter 19: Estimating Default Probabilities
This chapter is an update to Chapter 16 of the third edition. I find that at least
three hours of classroom time is necessary for the material. A number of approaches for
estimating default probabilities are considered: a) using historical data, b) using credit
spreads (from bonds, CDSs, or asset swaps), and c) using equity prices (Merton’s model).
One of the most important messages in this chapter is the difference between real world
(physical) and risk-neutral (implied) default probabilities. Real world default probabilities
are generally less than risk neutral default probabilities—but the difference between the
two varies through time. I spend quite a bit of classroom time going through Tables 19.4 to
19.6 and the arguments and the subsequent arguments on why there is a risk premium in
Table 19.6. The risk-neutral default rate for 1996 to 2007 is compared with the real-world
default rate for 1970 to 2013. The time periods do not match because a) the Merrill Lynch
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